ML20247J182

Provides Preliminary Results of NRC Special Projects Ofc Insp of RBCCW in Millstone Unit 2.Sys Vertical Slice Insp Was out-of-scope for Parsons Power Group,Independent Corrective Action Verification Program Contractor for Unit

ML20247J182
Person / Time
Site:	Millstone
Issue date:	04/20/1998
From:	Imbro E NRC (Affiliation Not Assigned)
To:	Bowling M, Miller H NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 9805210355
Download: ML20247J182 (9)

Text

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April 20,1996 Mr. Martin L. Bowling Recovery Officer - Millstone Unit 2 c/o Mr. Harry Miller Director - Regulatory Affairs Nortneast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385-0128

Dear Mr. Bowling:

This letter provides the preliminary results of the U.S. Nuclear Regulatory Commission's Special Projects Office (SPO) inspection of the reactor building closed cooling water (RBCCW) in Millstone Unit 2. This system vertical slice inspection was out-of-scope for Parsons Power Group, independent Corrective Action Verification Program (ICAVP) contractor for Unit 2. The inspection was part of Tier 1 of the ICAVP oversight activities described in SECY-97-003,

Millstone Restart Review Process." The inspection was performed from March 2 to April 9, 1998. The detailed findings of the team will be documented in Inspection Report No. 50-336/98-202. You were provided with the results of the inspection at a public exit meeting on April 9,1998.

A summary of the team's preliminary findings is enclosed. Overall, the team concluded that the review of the RBCCW system as part of your Configuration management Plan was adequate and had accurately assessed the capability of the system to perform the safety functions required by its design basis; the condition of the system compared with its design and licensing bases; the accuracy of the as-built configuration compared to design drawings; and the compliance of system operations with the final safety analysis report and plant technical specifications.

The SPO staff will include these findings, along with the findings of other inspection activities, in its assessment of the effectiveness of your effort to reestablish the design and licensing bases of Unit 2. No response to the issues discussed in this letter is necessary. NRC Inspection Report No. 50-336/98-202) will provide the finalinspection results and any enforcement actions that require your response.

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. M. L. Bowling 1

If you have any questions or comments regarding the issues discussed in this letter, please contact me at 301-415-2379.

Sincerely, Eugene V. Imbro l

Deputy Director, ICAVP Oversight I

Special Projects Office Office of Nuclear Reactor Regulation Docket No. 50-336

Enclosure:

Team 2A Findings, Millstone Unit 2 Out-of-Scope Inspection cc: See next page l

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If you have any questions or comments regarding the issues disdusse3in1 bis lett r, please contact me at 301-415-2379, pygg,g

'26 Sincerely, N00h N

(griginal SW Eugene V. Imbro Deputy Director, ICAVP Oversight Special Projects Office Office of Nuclear Reactor Regulation Docket No. 50-336 I

Enclosure:

Team 2A Findings, Millstone Unit 2 Out-of-Scope Inspection cc: See next page Distribution:

Docket /PUBLIC)

SPO RF SCollins/FMiraglia JLieberman BBoger i

WTravers PMcKee SReynolds HEichenholz BMcCabe PKoltay RArchitzel i

PNarbut JNakoski RMcIntyre

[i DOCUMENT NAME: A:\\QKLK202. (*see previous concurrence )

To receive a copy of this document, indicate in the box "C" copy w/o attach /enci"E" copy w/ attach /enci'N" no copy,

OFFICE ICAVP:SPO ICAVP:SPO Tech Ed ICAVP:SPO SPO.DD SPp D l

hrhrs NAME PNarbu RArchitzel BCalure SReynoldsk Elmbr 4/ 998 4/ /98*

4/15/98*

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/98 2

DATE OFFICIAL RECORD COPY iL_________-___--___-_.--_------_____---_--_-----------------------.

Northeast Nuclear Energy Company Millstone Nuclear Power Station l

Unit 2 cc:

Lillian M. Cuoco, Esquire l

Senior Nuclear Counsel Northeast Utilities Service Company Mr. F. C. Rothen P. O. Box 270 Vice President -Work Services Hartford, CT 06141-0270 Northeast Utilities Service Company P. O. Box 128 Mr. John Buckingham Waterford, CT 06385 Department of Public Utility Control Electric Unit Ernest C. Hadley, Esquire 10 Liberty Square 1040 B Main Street l

New Britain, CT 06051 P.O. Box 549 West Wareham, MA 02576 Mr. Kevin T. A. McCarthy, Director Monitoring and Radiation Division Mr. D. M. Goebel Department of Environmental Protection Vice President - Nuclear Oversight 79 Elm Street Northeast Utilities Service Company Hartford, CT 06106-5127 P. O. Box 128 Waterford, CT 06385 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. David Amerine 475 Allendale Road Vice President - Nuclear Engineering King of Prussia, PA 19406 and Support Northeast Utilities Service Company First Selectmen P. O. Box 128 l

Town of Waterford Waterford, CT 06385 Hall of Records i

200 Boston Post Road Mr. Allan Johanson, Assistant Director j

Waterford, CT 06385 Office of Policy and Management Policy Development and Planning i

i Mr. Wayne D. Lanning Division Deputy Director of Inspections 450 Capitol Avenue - MS# 52ERN Special Projects Office P. O. Box 341441 475 Allendale Road Hartford, CT 06134-1441 King of Prussia, PA 19406-1415 Mr. M. H. Brothers Charles Brinkman, Manager Vice President - Operations Washington Nuclear Operations Northeast Nuclear Energy Company ABB Combustion Engineering P.O. Box 128 12300 Twinbrook Pkwy, Suite 330 Waterford, CT 06385 Rockville, MD 20852 Mr. J. A. Price Senior Resident inspector Unit Director-Millstone Unit 2 Millstone Nuclear Power Station Northeast Nuclear Energy Company clo U.S. Nuclear Regulatory Commission P.O. Box 128 P.O. Box 513 Waterford, CT 06385 Niantic, CT 06357

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Northeast Nuclear Energy Company Millstone Nuclear Power Station Unit 2 cc:

Mr. B. D. Kenyon Attorney Nicholas J. Scobbo, Jr.

Chief Nucler Officer-Millstone Ferriter, Scobbo, Caruso, Rodophele, PC Northeast Nuclear Energy Company 1 Beacon Street,11th Floor P.O. Box 128 Boston, MA 02108 Waterford, CT 06385 Citizens Regulatory Commission ATTN: Ms. Susan Perry Luxton 180 Great Neck Road Waterford, CT 06385 Deborah Katz, President Citizens Awareness Network P. O. Box 83 Shelburne Falls, MA 03170 The Honorable Terry Concannon Co-Chair Nuclear Energy Advisory Council Room 4035 Legislative Office Building I

Capitol Avenue l

Hartford, CT 06106 l

Mr. Evan W. Woollacott j

Co-Chair i

Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc.

Millstone - ITPOP Project Office P. O. Box 0630 Niantic, CT 06357-0630 Mr. Daniel L. Curry Project Director Parsons Power Group Inc.

2675 Morgantown Road Reading, PA 19607 Mr. Don Schopfer Verification Team Manager Sargent & Lundy 55 E. Monroe Street Chicago,IL 60603

]

l Team 2A Findings l

Millstone Unit 2 Out-of-Scope inspection

{

1. Background

Before the staff of the U.S. Nuclear Regulatory Commission (NRC) selected the reactor building closed cooling water (RBCCW) for the out-of-scope inspection on September 19,1997, the licensee had already identified and resolved many important design vulnerabilities. For example, the licensee had reanalyzed system flows, determined that some flows were inadequate and then increased flow to those components by increasing piping sizes. Similarly, the licensee and had analyzed new failure scenarios and made modification and procedural changes to resolve them. Also, the licensee had reperformed design basis calculations (e.g., RBCCW peak l

temperature) and reconciled the changed results. Similarly, the licensee studied l

generic issues (e.g., containment air cooler waterhammer) and reconciled the results down to the component level (piping and supports). The licensee had addressed past problems with high system pressure and frequent relief valve lifting, in addition, they added large relief valves to resolve an inter-system loss-of-coolant accident (LOCA) scenario in which a failed thermal barrier heat exchanger would overpressurize the RBCCW system. Similarly, the licensee provided backup air supplies for the valves that isolate the shutdown cooling heat exchangers to ensure that the safety function would be met in the event of a loss of instrument air. The licensee added check valves to isolate the nonseismic makeup water supply to prevent RBCCW inventory loss if the makeup water system failed.

The team was aware at the beginning of the inspection that not all problems had been analyzed and resolved. The licensee's letter of March 2,1998, to the NRC identified unfinished work. For example, the licensee indicated that important program reviews, such as high-energy line break analysis and environmental qualification reconciliation were not completed. It also indicated that certain activities such as calculations, modifications, and operator training would not be completed. In addition, at the start of the inspection, the team identified other areas that had not been completed and that had not been identified in the licensee's letter of March 2,1998. For examp!e, the team found that calculation and actions required for the failure of an RBCCW pump to start had not been analyzed. Likewise, the calculation for the heatup of the spent fuel pool had not been completed. In view of the status previously discussed, the team concluded that sufficient information was available to inspect and evaluate the adequacy of the licensee's review of the RBCCW system; the capability of the system to perform the safety functions required by its design basis; the condition of the system compared with the design licensing bases; the accuracy of the as-built configuration compared to design drawings; and compliance of system operations with the final safety analysis report (FSAR) and plant Technical Specifications (TSs).

Enclosure i

I l 2. Findings The team identified nine preliminary findings. Some findings had multiple examples.

These findings were judged to be Level 3. (Level 3 findings are those that reflect a j

departure from a design or a licensing basis but that do not affect the operability of the i

system or a train of the system.) The significance level and the number of findings may change in the final report as a result of further management review.

The licensee had identified many system problems in its Configuration Management Plan (CMP) review of the RBCCW system. When the team identified a problem that the l

CMP had already identified, the team did not issue a finding.

2.1 Finding 1 l

a. A post-modification test was inadequate. The test for the addition of backup air supplies for the shutdown cooler isolation valves did not ensure that the design assumptions would be met, i

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b. A periodic maintenance test did not have acceptance criteria. The periodic l

examination of the service water side of the RBCCW heat exchanger did not have acceptance criteria for the amount of acceptable as-found debris.

c. The RBCCW flow balarice test was not required to be periodically reverified.

The system does not have installed instrumentation to verify adequate flow to l

each critical component.

i I

2.2 Finding 2

a. The potential adverse waterhammer effects of a delayed manual RBCCW pump start (after a LOCA concurrent with a loss of offsite power) was identified by the licensee in a 1997 licensee event report. However, the action item to study those effects was closed without the analysis being performed.

b. A change to the RBCCW operations procedure to correct pressure spikes and relief valve lifting was inadequate. The procedure change was not tested for effectiveness, the relative importance of the system pressure versus the flow had not been fully assessed, the change was not compatible with inservice test procedures, and the revision conflicted with a statement in the FSAR.

. 2.3 Finding 3 FSAR Table 9.3.1 was not updated to show the correct RBCCW mass flow e

rate.

2.4 Finding 4 Valve RB-402 was known as valve CH-223 on several licensee databases e

and in the FSAR. Valve RB-402 was listed as safety-related, but valve CH-223 was not.

2.5 Finding 5 The team identified four examples of work that was not performed or installed in accordance with requirements:

a. Two RBCCW pressure instruments in two containment penetrations were not classified as seismic or safety-related as required by the FSAR.

b. One instance was identified in which cable separation did not meet requirements.

c. An elbow reducer and a pipe support were not installed as shown on their drawings. These were originalinstallations,

d. Two pipe supports were not installed as shown on their drawings. These supports were installed during the current outage.

2.6 Finding 6

a. The instrumentation alarm setpoint calculation for the RBCCW radiation monitor was inadequate. The setpoint calculation did not account for sample dilution.

b. The flow assumed in the setpoint calculation had not been controlled by the operating procedures.

L_____

-4 2.7 Finding 7 The team identified two examples in which procedures were not adequate:

a.

annunciator response procedures for the RBCCW were deficient f

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b. procedures were not consistent with each other nor with the abnormal operating procedure for the RBCCW 2.8 Finding 8 A controlled document library had out-of-date drawings. The piping and e

instrument diagrams that were also out-of-date.

2.9 Finding 9 The simulator software had not been updated to indicate the increased l

e RBCCW flow rate to the engineered safety features room coolers.

2.10 Finding 10 There was no formal procedure for controlling locked valves. This finding will e

be reported by the NRC resident staff in its next report. The finding is being combined with other examples of a lack of procedures.

3. Unresolved item 3.1 Finding 11

a. The team noted a failure to identify an unreviewed safety question while l

performing the safety evaluation for a specification change. The change reduced the electrical cable separation criterion from 12 to 6 inches inside cabinets.

b. The team noted a failure to perform a safety evaluation for two modifications.

The modifications included the addition of seismic supports to the RBCCW surge tank and a change in the orifice size in the RBCCW pump recirculation line.

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thatwere notviolations but wer

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Om observed a number ofitems lculations of record on site. It p astrate an acce I

l nned to lnipection. For example -

Thalicensee did not have allthe cato notify the NRC and d rctri3vs them before restart orrationale for the mis rading itsinstrumentation setpo l tions.

int calculation Thalicensee was committed to upgithits owner's group programto bein accordance w regarding the actions require oblemwas ice water during a LOCA. This pr functional Th3 licensee came to a conclusion during alicensee safety system dures would d that a change in perating proce the scenario of aloss of serv J

idcntified on February 19,1998,r view. Thelice o

i resolve the problem.

din an A

e RBCCW systemwas goo General on 5.1 o The team noted thatlabeling disciplines.

land thorough.

l Electrical luations reviewed werelogica l

past 2 years 5.2

a. The electricaltechnical eva i alreviews performed during thed in nature.

b. Thelicensee's broad electr ccomprehensivein dep were CCW Instrumentation intenance, and design of the RB 5.3

a. The physicalcondition, ma ellent instrumentationwas good. l technicians demonstrated

b. Instrumentation and contro housekeeping a l-i u________________________

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